What HMRC looks for during an AML supervision visit
Mehmood Rajoka10 min readUpdated May 2026
In brief: HMRC AML inspectors check 8 main areas: written AML policy, firm-wide risk assessment, CDD records, PEP and sanctions screening evidence, Enhanced Due Diligence, record keeping, MLRO appointment, and staff training.
Key points
- HMRC checks 8 areas: AML policy, firm risk assessment, CDD records, screening evidence, EDD, record keeping, MLRO, and staff training
- Inspectors want existing records — not explanations of what you would have done
- A generic AML policy that does not match your practice is a common finding
- Good records reduce risk but do not guarantee a clean result
- Certivus structures and stores the client-level evidence HMRC asks for
A practical guide to the 8 areas HMRC checks during an AML inspection and how to prepare your accountancy practice.